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Compliance Activities and Policy

Preface

In the current changing business environments, it is required of companies to have higher ethical minds and sense of social responsibilities.
It means that each individual not merely shall maintain the public order, but must conduct in good faith, having Corporate Philosophy in common, following sincerely the sense of value and ethical standard required of him/her as a good member not only of a company but of the society.
To cope with these environments, in October 1997, Clarion Headquarter has set up a “Corporate Philosophy” as the cornerstone of company management and applied it to all Clarion Group of Companies.
Business activities of a company must always be in done in the interest of maintaining good relationships with various stakeholders such as customers, shareholders, business partners and employees.
In addition, it is required of companies to establish a Corporate Governance System that can be accepted in a global sense.
Today, we establish the Compliance Program to put our group “Corporate Philosophy”, which has been the basic concept for our activities for a long time, into practice. At the same time, we draw out this Guiding Principles of Conducts and Behaviors (herein after called “the Principle”) as prescription for our actual carrying out the program as basic foundations for our responsibility to the society and corporate morals. 
 
April 01, 2004

1. General Rules

Basic Points
 
(1) As a member of the international community, we shall be conscious at all times to observe all laws, rules and regulations, and also treaties and laws of foreign countries, where applicable.
(2) We shall recognize fully the Corporate Ethics, which is required of our company, and shall conduct ourselves in good business and social sense and be guided by our responsibilities as members of the society. We are cognizant that action that is not a violation of the law may still be deemed a violation of Corporate Ethics.
(3) In the event a legal violation or anti-social activity occurs, we shall take corrective action promptly, make a preventive plan of relapse, and deal with the violation in a strict manner. There is no exception to this standard, even if the action was undertaken in the interest of making the company better, or under the instruction of a supervisor. We shall not neglect to address any violations.
 

1) Observance of the Social Criteria

We shall not only observe laws, rules and regulations, but also respect social criteria, and conduct and behave ourselves with decent business sense.

(1) We shall observe and abide by all laws, rules and regulations both at home and abroad.

(2) We shall fully recognize the Corporate Ethics required of our company, and shall conduct and behave ourselves sensibly and responsibly as members of the society.

2. Relationship with the Society

Basic Points
 
(1) Our company has made a pledge in our Corporate Philosophy to contribute towards a prosperous society by creating valuable products. We can contribute to society through proposals of new value which can win the empathy of our customers and society.
(2) In order to do so, it is always required that we not only produce products with outstanding technical capabilities, but also put the highest priority on the future of humanity, society and the earth. We also require fair, open and highly transparent dealings in our corporate activities. Higher corporate transparency means making a closer connection to the people related to our company (Stakeholders) such as stockholders, business partners, customers and the communities within which we work, and to disclose faithfully, useful and pertinent company information to these entities.
(3) Clarion Asia Pte. Ltd., including our parent company and other Clarion affiliates and subsidiaries, will strive to become companies that are well accepted by each of our respective communities.
 
1) Contribution to the Society
We shall, as members of a corporate citizenship, actively take part in activities to help make the society better and contribute to its well-being and improvement.
(1) We shall fulfill our role as members of a corporate citizenship by continuously conducting social service activities such as supporting culture and arts, participation in volunteer activities, and contribution to the international community through sponsorships and donations.
 
2) Observance of Business Related Laws, Rules and Regulations
We shall observe local laws, rules and regulations related to our products and services.
(1) If the business is under the influence of various laws, rules and regulations, we shall observe them, and make sure to fulfill necessary requirements with the related agencies, such as issuing of notification or application for approval.
 
3) Observance of Laws and Regulations related to General and Political Contributions and Donations
We shall observe local laws and regulations when making political and other contributions and donations to various organizations.
(1) When it is required to execute any kind of contributions and donations, we shall follow the internal company standards and obtain the approval by the company.
(2) We shall not offer bribes, make illegitimate profit transfers or political donations to public administrators. We shall also strictly refrain from any deeds that might be seen as collusion with a political office or public administrator. Our relationship with holders of political office and public administrators shall be sound and clear.
 
4) Breaking off Relationships with Groups and Organizations with Anti-Social Beliefs and Activities
We shall deal with fortitude groups and organizations whose beliefs and activities are disruptive to the established social order and to avoid any relationship with them.
(1) In order to avoid involvement in illegal or anti-social acts, we shall try to equip ourselves with some basic legal knowledge, apart from social common sense and sense of justice, and shall always take a sensible course of action.
(2) We shall not, at any time, associate with or conduct business with groups or organizations with anti-social beliefs and activities even for the sake of our company and for our own advantage.
(3) We, also, shall never have any business with the traders who have some relationships with groups and organizations with anti-social beliefs and activities.
(4) We shall also not engage indirectly in any business with organizations with anti-social beliefs and activities through third parties such as traders, friends and relatives.
(5) We shall act with resolute attitudes when we receive unreasonable requirements from groups and organizations with anti-social beliefs and activities. And at the same time, we shall never try to settle with them by money.
 
5) Protection and Preservation of Environment
In order to maintain a sound relationship with the environment, we shall be aware of the importance of protection and preservation of nature at all time in corporate activities such as research, development, manufacturing, sale and disposal of our products. We shall engage in environmental-friendly manufacturing activities complying with related environmental treaties, laws and regulations.
(1) When we research, develop, manufacture, sell or dispose our products, we shall always recognize the importance of the protection of environment, shall observe all treaties and laws related to the environment, and engage in environmental-friendly manufacturing of our products. We shall also restrain from waste generation throughout product life cycles by focusing on the rule of producer’s extended responsibilities.
(2) We shall focus on environmental consciousness and shall participate in activities that protect the environment such as buying recycled products, using energy efficient office equipment, recycle used office products and paper, saving papers by utilizing paper-less measures, and collecting garbage separately by the kinds of them.

3. Relationship with Customers, Business Partners and Competitors

Basic Points
 
(1) Our company is aiming to have impartiality and higher transparency in our corporate activities by which we can prove ourselves worthy of the trust of every customer and trader. Namely, in relationships with business partners, in order to enhance transparency, we shall at all times, make fair and impartial business decisions based on clear and objective criteria.
(2) Also, as business partners are not only our collaborators, but also our customers, we shall strive to build reliable relationships with them. Close communication, coupled with a focus on strengthening the business relationship, can bring mutual prosperity.
(3) Furthermore, in order for us to be recognized as a company beneficial to society through our global community service efforts, and in order to be a welcome member of our communities, we shall strengthen our business relationship with local enterprises.
 
1) Sincere Dealing with Customers
We shall, at all times, be sincere in dealing with our customers and offer them excellent customer satisfaction and pleasure through superior products and services.
(1) We shall always strive to accurately assess our customer’s needs and deliver products and services with qualities that satisfy those needs.
 
2) Offering Safe Products
We shall, at all times, be aware of the nature of our products and safety requirements related to them. We shall understand and observe laws and regulations related to product safety standards and strive to always create safe products.
(1) When we manufacture, develop, import, stock, sell, transport, export, mend or repair products, we shall always pay attention to safety, fully understand and observe any laws and regulations related to the product safety, and always strive for higher safety levels.
(2) If we obtain any information related to product safety issues, we must verify the information at once. If we have clear evidence of a product safety concern, we shall inform the department concerned and take suitable countermeasures. 
 
3) Observance of the Anti-Monopoly Law
We shall, at all times, prevent misuse of monopoly or market power through cartels, illegal conferences, forcing re-sale prices or abuses of a superior business position. We shall engage ourselves in fair and free trade competitions.
(1) We shall not make any unfair restriction of trade by participating in a conference among fellow traders or trade associations to arrange prices, quantities or manufacturing facilities, or by collusive bidding among those.
(2) We shall not take any action in conspiracy with fellow traders or trade associations to reject business with any particular company (ex. special discount sales company) or newcomer, nor shall we unfairly restrain resale prices by resellers.
 
4) Appropriate Dealings with Vendors and Observance of Laws Protecting Subcontractors
We shall, at all times, deal with our vendors openly and fairly with sensible and sincere manners.
(1) We shall select most adequate vendors by impartially comparing and evaluating all applicable conditions of quality, price, delivery, engineering and developmental capability, stable supply chain, environmental preservation and the like.
(2) No matter whether we have the power or not to influence the selection of vendors, we shall never make use of such power to provide advantageous treatment to one vendor over another.
(3) When we make the consignment base business activity and purchase commodities, we shall always be aware of specific contractual obligations with vendors and shall be conscious to avoid actions that violate the contract. 
 
5) Avoiding Unfair Competition
We shall, under no circumstances, illegitimately or illegally obtain trade secrets from other companies nor shall we misappropriate legitimately learned trade secrets.
(1) Under no circumstance shall we obtain and use other company’s secrets by fraudulent methods such as thefts.
(2) We shall not obtain or use other company’s secrets including plagiarism if we know that they were obtained or that they might have been obtained by such fraudulent methods.
 
6) Observance of Reasonable Limits to Entertainment and Presents
We shall not entertain or give presents to, nor receive entertainment or presents from customers or business partners beyond reasonable limits socially accepted.
(1) When we conduct business entertainment or give presents to our customers, they shall not exceed generally acceptable social common sense levels.
(2) When we receive business entertainment or gifts from our business partners or vendors, we shall keep them down to less than generally acceptable social common sense levels.
(3) In encouraging impartial and transparent corporate activities and to avoid not only fraudulent conduct which might cause severe criticism by society, but also any action which might be perceived as fraudulent conduct, it is, in principle, prohibited for individual employees to receive gifts, benefits or entertainment which might directly influence the result of individual business transactions. 
 
7) Keeping Moderate Relationship with Public Service Personnel
We shall not entertain or give presents to government agents, public service personnel, officers or local public organizations either domestically or overseas where the law may prohibit this act.
(1) We shall not entertain or provide gifts to public service personnel or officers if such acts are forbidden by the law.
(2) We shall not attempt to influence public service agents of foreign government or local public organizations with money, gifts or entertainment in return for consideration beneficial to the company or for personal gain.
 
8) Verification of Appropriate Advertisements
We shall, at all times, use fair and proper expressions in advertisements, and verify, based on facts, the appropriateness of all advertisements.
(1) We shall never use incorrect explanations or descriptions in our advertisements that may abuse or slander another company. Additionally, we will never use any term that predicates social discrimination in our advertisement activities.
(2) Before we make comparative advertisements, we shall make sure that the content is proven by the facts and that they must be faultless, adequate and avoid misleading statements.

4. Relationship with Shareholders and Investors

Basic points
 
(1) We have indirectly been working with Japan headquarter (HQ) in driving their IR (Investors Relation) program to release company information beyond what is required of laws to all of shareholders and investors. In doing so, while maintaining our management accountability, we are trying to release this information in timely manner to (HQ), and supporting their efforts in improving transparency of the management and to enhance shareholder and investor understanding of our business activity.
(2) We shall collect information broadly and use all of those at our discretion and shall put it together effectively for HQ to communicate with our shareholders and investors. 
 
1) Disclosure of Management Information
We shall, through Clarion HQ, disclose management information on our operations and financial situations to shareholders and investors in an accurate and timely manner . We shall convey our Corporate Philosophy and Management Policies to them clearly and definitely. We shall listen comments and criticisms against the information disclosed in a sincere manner.
(1) With the aim of impartial and transparent corporate activities, we shall, based on the facts, release accurate and timely information about our products and technologies, business details, financial situation and service activities to the community, to those who have a relationship with our company.
(2) Each employee shall be conscious that he or she plays a part of public relations. Each employee will also aggressively support the company’s release of information to the best of their ability.
(3) In preparation for releasing of information in adequate and timely manner, every document and information which come from each of the departments in-charge shall always be made accurately and honestly based on the facts.
(4) We shall take all criticism by our shareholders and customers seriously, and promptly relay such information to the appropriate department.

5. Relationship with Employees

Basic points
 
(1) Employees are fundamental of all corporate activities for our company, we shall show necessary and sufficient respect for them, and shall positively support their personal and career growth.
(2) Although there are various elements to satisfy each individual employee, from the fundamental employment benefits such as compensation, to opportunities for them to achieve self-actualization, we shall support each employee and his or her growth as a human being by providing an environment where each individual employee can demonstrate his or her own best ability through their job.
(3) For that purpose, we shall respect all basic human rights, observe all laws, especially laws related to labor and employment, and maintain internal order and discipline by observing internal rules. We will also allow for a work environment where each individual can show his or her best efforts, perform faithfully his or her job and to continue to develop skills to maximize their ability. 
 
1) Respecting Human Rights and Equality
We shall, at all times, maintain a sound working environment, and respect human rights, equality and personality of each individual.
(1) Clarion will make employment and employment-related decisions without regard to characteristics that laws require employers not to consider. They include such things as an applicant’s or employee’s race, color, religion, age, sex, national origin, sexual orientation, or disability, or any other basis like hobbies and school careers prohibited by applicable all laws.
(2) We shall never compel anyone to work by actions such as threats of violence, abuse, or slander and shall also never infringe upon human rights by bullying or harassing.
 
2) Prohibiting Sexual Harassment
We shall, at all times, abstain from words and behaviors that might give sexual unpleasantness to others.
(1) We shall, at all times, abstain from behaviors, words or remarks that are suggestive and which constitutes an unwelcome sexual advance or request for sexual favors, or any verbal, visual or physical conduct of a sexual nature that is (1) related to or conditional to the receipt of employee benefits, or (2) sufficiently severe or pervasive as to alter the conditions of employment and create an abusive working environment.
(2) We shall condemn any abuse of powers by employees who use their position of influence as a threat for sexual favors. 
 
3) Protection of Personal Information
We shall, at all times, strictly control the confidentiality of personal information of employees and other outside personnel and the information that we come to possess in the course of our business activities.
(1) We shall strictly control all personal information we come to possess in the course of business and ensure that it is kept confidential.
 
4) Maintenance of Safe and Clean Working Environment
We shall maintain a safe and clean working environment with the understanding and observance of related laws and regulations.
(1) We shall maintain the working environment safe and clean as a top priority matter, and shall understand and observe the laws and regulations related to the safety and cleanliness in all business execution.
(2) In the event of a workplace accident, we shall minimize the influence from, investigate the cause of the accident thoroughly and put measures in place to prevent a recurrence.
 
5) Observance of Laws, Rules and Regulations Related to Labor and Workers
We shall observe all laws, rules and regulations related to labor and employment, and maintain a safe and pleasant working environment.
(1) We shall thoroughly administrate each individual’s working hours and days not exceeding those designated by Employment Act.
(2) We shall always let all supervisors pay attentions to their workers’ health conditions, mentally and physically.
(3) We shall abide by the Singapore Employment Act which spells out the rights and obligations of employers and employees and the basic terms and conditions of employment wherever applicable.
 
6) Rigid Distinction of Company and Private Matters
We shall make rigid distinction between company and private matters, and shall at no time bring personal interests into, or take company matters out of work.
(1) We shall make clear distinction between company matters and private matters, and shall not mix these matters.
(2) We shall never divert company expenses to private eating or drinking, nor shall we make use of company equipment for private matters.
(3) We shall never bring the company position into private, and shall also never involve subordinates into own private purpose.
(4) We shall not let private matters implicate the company and tarnish its reputation.

6. Relationship with Company and Company Properties

Basic points
 
(1) With the recognition that our company exists with the mission to contribute to society by offering valuable products, we shall build and maintain appropriate relationships with the stakeholders of our company.
(2) We shall observe our Corporate Philosophy, the Principle and other internal regulations.
(3) We shall adequately manage all company’s property, such as assets, information, documents and the like, and shall never use them unlawfully or improperly.
 
1) Observance of Company Rules and Standards .
We shall, at all times, observe company regulations and standards.
(1) We shall never commit any act that is prohibited by internal rules, regulations, policy, practice or standards, and never perform unlawful and unfaithful activity against those.
(2) In the event that a law, internal rule, regulation, policy, practice or standard is unclear, we shall address such questions to our direct supervisors or the appropriate department for clarification.
 
2) Following Proper Accounting Procedures
We shall follow proper accounting procedures complying with related laws, regulations, internal rules and standards in order to establish an effective internal cross-check system as well as to comply with external requirements.
(1) When we make an entry in a book or write out a slip, we shall make the entry accurately complying with related laws, rules and regulations, and also with internal rules and standards.
(2) We shall never make false or fictitious entry when reporting company accounts. Additionally, we shall never keep assets or liabilities off the books.
 
3) Prohibition of Activities with Conflicting Interests
We shall, at no time, engage ourselves in activities that compete with or conflict with our company’s business.
(1) We shall not work for the sake of our competitors and/or trading partners, and shall never have the pecuniary relation and/or a business with them without express instruction and permission by the company.
 
4) Prohibition of Political and Religious Activities
We shall, at no time, engage ourselves in political and religious activities inside company premises.
(1) An employee may not solicit for any cause or organization or distribute literature for any cause or organization during the working time of the employee who is doing the soliciting or the working time of the employee who is being solicited.
(2) Additionally, employees may not distribute literature at any time in working areas of the facility. 
 
5) Control of Confidential Business information
We shall, at all times, control confidential business information in an appropriate manner, and in no case, disclose this information to the outside without prior permission from the company.
(1) We shall strictly control the confidential business information of both our company and our business partners. We shall never disclose such information to outside entities, nor shall we use this information for purposes other than business.
(2) In the event we need to release confidential information to an outside entity, we shall require confidentiality agreements to be made with all parties so that we can prepare for unforeseen divulgement. 
(3) We shall never make fraudulent use of the corporate secrets of other companies.
(4) Even after an employee’s resignation from the company, he or she shall not disclose any confidential business information of either our company or other companies, and also shall not use them for any purposes.
(5) In order to prevent from leakage of such information by carelessness, we shall be aware of our surroundings when discussing confidential information while both in private and in public and shall never discuss this information anywhere it may be easily overheard.
 
6) Proper Administration and Deployment of Company Properties
We shall, at all times, maintain company property in safe working order and properly deploy these assets. Also, in no case shall we misappropriate them for personal purposes.
(1) We shall, at all times, deploy company properties only for the purpose of performing the business for which it is intended and only with the approval of a direct supervisor.
 
 
7) Proper Use of Information Systems
We shall use the company information system only for business purposes, not for the private purposes.
(1) We shall strictly control the ID and password connected to company information system, and prevent leakage of such data.
(2) We shall not use another person’s ID and password for fraudulent purposes or in any action that may violate that person’s privacy.
(3) With the popularization of information terminal, electronic mail, network and the like, in order to administrate properly and utilize digital information, we shall always maintain and upgrade secure information systems.
 
8) Proper Administration of Documents and Records
We shall, at all times, administrate documents, records and other information in a proper manner, always maintaining an understanding of their importance.
(1) We shall keep and protect documents and materials deemed as confidential corporate secrets. At the same time, we shall acquire outside documents and materials deemed confidential by others only by legitimate means.
(2) We shall compose, transmit, store and scrap any documents according to our written regulations and standards.
 
9) Protection of Intellectual Property Rights
We shall, at all times, protect intellectual property rights, acknowledging them as important assets.
(1) We shall protect all company intellectual property by prompt application for relevant patents.
(2) We shall not make, nor make use of, any unauthorized or fraudulent copies of computer software.
(3) We shall not use other company’s intellectual properties, nor violate their rights to intellectual property, without written agreement from the property holder.

7. Additional Rules

1) Scope of Application of the Principle
This Principle is applied in full to all employees of Clarion Asia Pte Ltd. It also applies to the personnel assigned to Clarion under contracts from other companies and to part-time and probationary employees, where applicable.
 
 
2) Modifications and Abolition of the Principle
This Principle shall be modified or abolished only after the approval at the Clarion Co. Ltd. Board of Directors Meeting.
 
3) Consultations and Reports
(1)In the event questions arise regarding the content and/or interpretations of the Principle, inquiries shall be addressed to the department administering affairs of compliance at Clarion Co. Ltd.
(2)In the event of a violation or threat of violation to the Principle, whether by individuals or groups, employees or outsiders, the individual discovering the violation (“Reporter”) shall report their facts to their departmental supervisor. It is the responsibility of the supervisor to insure that the facts are reported to a senior executive of the company. The Reporter may also report directly to the department administering affairs of compliance.
(3)The Reporter, as defined under the preceding clause, shall be protected from any disadvantageous treatment(s) due to the act of reporting.
 
4) Violation of Rules
Anyone in violation of the Principle shall be dealt with in accordance with company regulations in force at that time.
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